Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Cenvat credit on immovable property constructed after issuance of completion certificate is not permissible, as transaction is treated as sale of goods, not service. Cenvat credit can be taken only on receipt of inputs and within one year from date of documents. Extended period of limitation rightly invoked as appellant was aware of ineligibility for credit after completion certificate. Imposition of penalty u/s 78 and levy of interest upheld. Appeal dismissed by Appellate Tribunal.
Cenvat credit on immovable property constructed after issuance of completion certificate is not permissible, as transaction is treated as sale of goods, not service. Cenvat credit can be taken only on receipt of inputs and within one year from date of documents. Extended period of limitation rightly invoked as appellant was aware of ineligibility for credit after completion certificate. Imposition of penalty u/s 78 and levy of interest upheld. Appeal dismissed by Appellate Tribunal.
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